I
.
ORIGINAL
i‘;:~:r,‘,‘r[,
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
hG 18
4 z,- ;:;I qIE
/L!,,,~ ,,
Docket
MAILING ONLINE SERVICE
No. MC98-1
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS HAMM TO INTERROGATORIES OF
DAVID B. POPKIN
(DBP/USPS-TG-2-3)
The United States Postal Service hereby provides
Hamm to the following
interrogatories
filed on July 30, 1998.
Interrogatory
responses
of David B. Popkin:
DBP/USPS-TG-
of witness
DBP/USPS-TG-2-3,
1 was redirected
to witness
Seckar.
Each interrogatory
is stated verbatim
and is followed
Respectfully
by the response.
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
iL+d 7. &IL
Kenneth
475 L’Enfant Plaza West, SW.
Washington,
D.C. 20260-I
137
(202) 268-3083;
Fax -5402
August 10, 1998
N. Hollies
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS HAMM TO INTERROGATORIES
OF DAVID 6. POPKIN
DPBIUSPS-TG-2.
On line 18 of Page [sic] 2 of your testimony you state that
PIA members are eager to participate.
How many of the approximately 15,000 members were contacted to
a.
determine their response and desires?
How many members provided an unqualified eagerness to participate?
b.
How many members provided a desire to participate with reservations?
::
How many members indicated that they were reluctant to participate?
Response.
a-d.
In April 1998, a draft Request for Proposal was sent through the Mailing
Online Web site to the members of the PIA’s Digital Printing Council
(DPC) and to the DPC Steering Committee
and Vendor Advisory
Committees.
This program focuses solely on digital printing and its
applications
(i.e., Mailing Online).
approximately
The total number mailed, was
250. The group was asked to make comments,
deletions
and additions to the request.
PIA’s Economics
Department
also tracks our members needs and
services, and the industry’s economic trends.
What the economists
have
found is that our members are always looking for new services in hopes of
finding new revenue sources.
Mc98-1
.
.
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS HAMM TO INTERROGATORIES
OF DAVID B. POPKIN
DBPIUSPS-TG-3.
what compensation,
Since you are potentially a printing contractor for this service,
if any, has the Postal Service paid you for your testimony?
RESPONSE.
None.
I am a volunteer leader at PIA and receive no compensation.
currently the Co-Chair of the Digital Printing Council.
Mc98-1
I am
.
DECLARATION
I, John Hamm, declare under penalty of perjury that the foregoing
true and correct, to the best of my knowledge,
information,
and belief.
answers are
I
.
CERTIFICATE
I hereby certify
participants
OF SERVICE
that I have this day served the foregoing
of record in this proceeding
in accordance
with section
of Practice.
ILLri? d/i
Kenneth
475 L’Enfant Plaza West, SW.
Washington,
D.C. 20260-I
137
August 10, 1998
document
N. Hollies
upon all
12 of the Rules